What is the range of awards for the loss of services of a spouse in a consortium?

Alberta, Canada


The following excerpt is from Woelk v. Halvorson, 1979 ABCA 333 (CanLII):

All of the courts recognize that there are many rights bundled up in the word "consortium". In reading the cases all of the awards are very small, a number of the English awards are as low as £20 to £40. The largest English award is £5,200 in Lawrence v. Biddle (1966) 1 All E.R. 575. In that very sad case the wife was virtually a vegetable as a result of terrible injuries. Her mental state was reduced to that of a child of 3 to 5 years of age. The wife was confined to an institution. The husband was left with a young family. He required a full-time housekeeper. The award of £5,200 was really £5,000 for the loss of services of his spouse as a wife, mother and homemaker. His costs in replacing her as a homemaker were very substantial. For this he received £5,000 and the additional £200 was for a period of at least three years almost total loss of her comfort and society.

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